JUDGMENT Anil Kumar, J. - Heard Sri Ratnesh Chandra holding brief of Dipak Seth, learned senior counsel for the petitioner and Sanjay Sareen, learned standing counsel appearing for the respondent. The brief facts of the case as stated by learned counsel for the revisionist are that Sri Chandramani Kant Singh, revisionist, is a descendant of Raja of Bhinga Raj in District - Bahraich (now district Shrawasti) and he has inherited the properties of the said Raj including the groves situated in various villages in the year 1982-83. In view of the abovesaid background a notice under section 7(3) of the U.P. Trade Tax Act, 1948 was issued to the revisionist for the assessment year 1982-83. In response to which the revisionist had submitted his reply, inter alia, stating therein that he is neither a "dealer" as defined under section 2(c) of the Act nor the sale of standing green trees by way of auction was a business, so he is not liable to be assessed for tax under the provisions of trade tax. Further, initially the assessing authority after taking into consideration the provisions of section 7(3) of the Trade Tax Act had passed the assessment order on the basis of the assessment. Thereafter, the order which was passed on the basis of assessment against the revisionist was confirmed by the appellate authority in the appeal and thereby by the Tribunal. After submission of reply and on the basis of material and documentary evidence on record the assessing authority passed the assessment order dated March 29, 1985 for a tax of Rs. 25,200 for the assessment year 1982-83. Aggrieved by the order dated March 29, 1985 the revisionist preferred an appeal before the Assistant Commissioner (Judicial) under section 9 of the Act before the appellate authority (Appeal No. 427 of 1982-83) and the same was dismissed by the order dated March 17, 1990. Aggrieved by the aforesaid order the petitioner had filed a second appeal before the Trade Tax Tribunal, Bench III, Lucknow (Second Appeal No. 511 of 1990 (1982-83)) which was dismissed by order dated March 14, 2001. Aggrieved by the aforesaid order the petitioner had filed a second appeal before the Trade Tax Tribunal, Bench III, Lucknow (Second Appeal No. 511 of 1990 (1982-83)) which was dismissed by order dated March 14, 2001. Aggrieved by the order dated March 14, 2001 the present revision was filed by the revisionist before this court under section 11(1) of the U.P. Trade Tax Act, 1948 on the following questions of law : (1) Whether selling of standing green trees by the revisionist by way of auction amounts to selling of timber or wood within the meaning of the U.P. Trade Tax Act, 1948 and liable to trade tax ? (2) Whether if in the felling permission granted by the D.F.O. in respect of several trees which are spread over several villages then will it amount to grant of permission of felling of trees of a forest ? (3) Whether the grove land of the revisionist in different villages can be treated as forest in case the permission of felling the trees is granted by the D.F.O. in respect of several trees at a time ? (4) How and when a land is to be defined and treated to be a forest land by the trade tax authorities ? The learned counsel for the revisionist Sri Ratnesh Chandra had challenged the order passed by the Tribunal mainly on the following grounds : (a) The revisionist does not come within the category of "private owner of forest" as the grove cannot be said to be a forest and as such was not liable to be assessed to trade tax, (b) That simply because of the fact that the trees which were auctioned by the revisionist were scattered over five villages and the distance of one tree with the other was about three kilometres does not mean that it was on a forest land, (c) That the standing green trees sold by the revisionist in the auction were on the ancestral grove of the Bhinga Raj. Accordingly, the order under challenge in the present revision deserves to be set aside. Accordingly, the order under challenge in the present revision deserves to be set aside. On the other hand learned counsel for the respondent Sri Sanjay Sareen has submitted that the Tribunal after considering the entire facts and circumstance of the case has rightly came to the conclusion that the land, which was held by the revisionist comes within the definition of "forest" as given under section 38(a) of the Indian Forest Act, 1927 and thus trees, which were sold by him fall within the definition of "goods" as given in section 2(d) of the U.P. Trade Tax Act, so the order passed by the Tribunal is perfectly valid and in accordance with law and needs no interference. I have heard learned counsel for the parties and perused the record. In the present case, the controversy, which is involved is whether the land which of the revisionist comes within the ambit and scope of definition of "forest" as given under section 38(a) of the Indian Forest Act or not. From perusal of the judgment passed by the Tribunal under challenge in the revision it is clear, the Tribunal had given a categorical finding that the land involved in the present case comes within the ambit and scope of the definition of "forest" as given under section 38(a) of the Indian Forest Act and further the Tribunal has also held that the trees, etc., which were standing on the land in question falls within the ambit and scope of the "goods" as per the definition as given under section 2(d) of the U.P. Trade Tax Act. It is well-settled proposition of law that while adjudicating and deciding the revision under section 11 of the Trade Tax Act this court can exercise the power of judicial review in order to interfere in the order passed by the Tribunal when the question of law is involved only and not on the question of fact. In the case of Commissioner of Sales Tax, U.P. v. Kumaon Tractors & Motors [2002] 9 SCC 379 the honourable Supreme Court has held as under : "... It appears that the High Court ignored the provisions of section 11 of the Trade Tax Act which confers limited jurisdiction to interfere with the order of the Tribunal only on the question of law, that too the said question of law is required to be precisely stated and formulated. It appears that the High Court ignored the provisions of section 11 of the Trade Tax Act which confers limited jurisdiction to interfere with the order of the Tribunal only on the question of law, that too the said question of law is required to be precisely stated and formulated. Instead of deciding the question of law, the High Court simpliciter reappreciated the evidence and ignored the material documents maintained and produced by the assessee, that is, books of accounts, bills and form C submitted by it. In this view of the matter, the impugned order cannot be sustained." In the case of Hari Steel Industries, Aligarh v. Commissioner of Trade Tax [2010] 33 VST 213 (All); [2008] UPTC 1050 this court has held that : "The assessing authority as also the Tribunal have considered the material on record in arriving at the finding of not accepting the account books and making an estimation of turnover which are pure finding of fact not warranting any interference in revisional jurisdiction. The findings recorded by the assessing authority and the Tribunal are not without basis and, therefore, do not warrant any interference." In the case of New Plaza Restaurant v. Income-tax Officer [2009] 309 ITR 259 (HP) and in the case of Zora Singh v. Commissioner of Income-tax [2008] 296 ITR 104 (P&H) the court has observed the estimation is a question of fact. The said view was further reiterated by this court in T.T.R. No. 163 of 2007 (CTT v. Chaudhary Brick Field, Gonda) decided on July 30, 2009 and T.T.R. No. 91 of 2005 (Commissioner of Trade Tax, Lucknow v. Swastic Enterprise Jain Dharmshala Bhawan Charbagh, Lucknow) decided on July 28, 2009 wherein it was held that estimation is a question of fact. Accordingly, in view of the abovesaid facts, the controversy, which is involved in the present case comes under the category of estimation done by the authorities under the Trade Tax Act, hence in view of the fact stated hereinabove no interference is required in the order passed by the Tribunal. Accordingly, the present revision filed by the revisionist lacks merit and is dismissed. No order as to cost.